STJ Jennifer E. (“Publius”) Siegel has a 32 (count ’em, 32) page small-claimer. I’ll let Her Honor judge-‘splain.

“The simplest version of this small tax case Opinion is that petitioners are liable for the deficiencies determined by the Internal Revenue Service (IRS) for each of the four years before us because they failed to meet their burden of proof and establish entitlement to any of the deductions claimed. If that were the whole story, however, this Opinion would not be 32 pages long. There is also a fraud penalty at issue for each year, and that requires a few more pages to discuss what petitioners claimed on their tax returns and to make clear how the IRS proved fraud by clear and convincing evidence. But really, this Opinion is long because one of the factors we consider in evaluating fraud is the sophistication of the taxpayer. And Mr. Janangelo is a pretty sophisticated taxpayer; Mr. Janangelo is an auditor at the IRS.” Peter J. Janangelo, Jr. and Mary Ann Janangelo, T. C. Sum. Op. 2026-8, at p 2.

Mr. Janangelo is also a CPA and a member of the Bar of Our Fair State.

“Mr. Janangelo was employed full time at the IRS during the years at issue and, at the time of trial, had been for almost 20 years. In his capacity as a revenue agent for the IRS, Mr. Janangelo conducts audits and reviews tax returns. He belongs to the National Treasury Employees Union (NTEU) and has been a union steward.” T. C. Sum. Op.  2026-8, at p.2. (Footnote omitted, but it says he works for IRS, not OCC.) 

I’ll spare you the rest, barring two points for audit.

“Mr. Janangelo argues that he is not required to substantiate any expense under $75, no matter what the category. He cites no authority for this proposition.” T. C. Sum. Op. 2026-8, at pp. 15-16.

Notwithstanding Section 446, requiring cash basis taxpayers to recognize income and expense when paid, ” Mr. Janangelo argued that the IRS should have been more flexible during his audits, explaining that his own audit practice working for the IRS is to allow a deduction, even if claimed for  the wrong year. Mr. Janangelo’s practice as a revenue agent may be to allow such deductions, but the Court’s role is to apply the law as written to the facts put in evidence. The Janangelos find support in neither.” T. C. Sum. Op. 2026-8, at p. 18

.I do not recommend either position.